Whistleblower Policy

​Whistleblowers perform an important role as they are uniquely placed to expose improper conduct within organisations. Often the best source of information concerning inappropriate conduct is persons who work for or have dealings with an organisation. This site is designed to allow you to inform Computershare about known or suspected improper conduct within our organisation. Whistleblower disclosure is simple, and anonymous if you wish.

You should carefully consider whether your disclosure of improper conduct is based on well grounded information and is being made in good faith. Any deliberate false accusations are taken seriously and are considered as improper conduct itself. Disclosures in good faith will usually be protected by domestic law. If in doubt you are encouraged to seek advice and the Regional Whistleblower Officer can provide guidance about the relevant principles.

If you are a Computershare employee

If you are an employee of Computershare and you become aware of any conduct which you consider, in good faith, may be reportable conduct then you should initially raise it with a senior manager within your business division or function. In many cases, this should satisfactorily address your concern. If you believe that you have been subject to harassment, discrimination or bullying, then you should first raise the issue in accordance with your local HR grievance procedures.

Computershare also recognises that there may be issues of such sensitivity that you do not feel able to raise it with your senior manager or through your local HR processes or you may feel that a concern you have raised has not been adequately addressed. If that is the case, then you can contact your Regional Whistleblower Officer in accordance with the processes above.

If you are an external party

If you are an external party and your report is assessed as relating to a concern or complaint about a product or service provided by Computershare rather than to Reportable Conduct, then the report will be referred to your local service concern department for further investigation and resolution.

What happens once you make a disclosure

When you make a whistleblower disclosure, it is assessed and investigated as appropriate.

The investigation process includes assigning an investigation team, conducting an investigation and if necessary recommending corrective action and then providing feedback to you on the outcome (if you have disclosed your identity).

Confidentiality

Computershare understands that maintaining the confidentiality of the whistleblower is necessary to avoid potential reprisals or detrimental action toward the whistleblower. If you raise a report under this policy then your identity and the information you provide will be shared only on a "need-to-know" basis as necessary for resolving the concern raised. All reasonable steps will be taken to protect your identity where the report is made in good faith.

What is improper conduct?

Improper conduct includes conduct which is:

Dishonest;

Fraudulent;

Corrupt;

Illegal;

Harassment, discrimination or bullying;

Unethical or otherwise has the potential to damage Computershare's reputation; or

In breach of Computershare policy, such as Computershare's Code of Ethics.

What is Computershare's policy on dealing with improper conduct?

Computershare adopts an absolute zero tolerance to inappropriate conduct within the organisation. It is our policy to actively detect fraud or improper conduct and to use every available disciplinary avenue to ensure that the offender is appropriately dealt with.

In line with this view, Computershare will take disciplinary actions against any person who commits fraud or engages in improper conduct. These disciplinary actions may include:

›Criminal prosecution and involvement of relevant authorities

›Dismissal

MORE INFORMATION

Click here for more information about Computershare's Whistleblower Policy.